Texas PUC Staff Proposal On Smart Meter Rules Would Decline REPs' Sought Language Prohibiting TDU Provision Of Value-Add Energy Usage Information To Customers Via SMT

Staff of the Texas PUC have filed a draft proposal for adoption in Rulemaking Project No. 48525, Rulemaking Relating to Advanced Metering, addressing AMI and Smart Meter Texas (SMT) issues

Staff proposes to reject a proposal from the Alliance for Retail Markets which had proposed that, "The prohibition against a TDU's provision of a competitive energy service should equally apply in the context of a web portal operated pursuant to 16 TAC § 25.130 [relating to advanced metering]."

"For example, a web portal should not compete with a REP's presentation of retail customer usage data through dashboards, graphs, email usage summaries, usage estimates, budget alerts, disaggregation services, benchmarking, charts, and other interactive tools. Otherwise, the REP will be competitively disadvantaged," ARM had said in proposing certain rule language to this effect

Staff recommended rejection of ARM's proposed language

"The commission declines to adopt ARM’s request to modify §25.130(d)(12) to specify that the prohibition on TDUs relating to provision of competitive energy services under §25.343 of this title applies to any service provided through SMT. The provision already properly addresses the issue raised by ARM. Furthermore, the commission agrees with the Joint ERCOT TDUs that the SMT business requirements approved in Docket No. 47472 clearly specify the way meter data must be provided and displayed on SMT," Staff said in a draft preamble

Staff's draft proposal for adoption removes the AMI requirement for a TDU to offer home area network (HAN) communication capability, except for a HAN device paired to a meter and in use at the time that the version of the web portal approved in Docket Number 47472 was implemented

Staff said that on-demand reads are an appropriate substitute for HAN functionality, and the proposal includes language requiring the provision of on-demand reads

Staff would also decline to adopt ARM’s proposal to revise §25.130(g)(1)(J) to permit REPs or customers to request that ERCOT TDUs support the pairing of a customer or REP-provided device to an AMS meter, because the commission is eliminating the requirement that an AMS meter be capable of pairing with a customer or REP-provided device.

Staff would decline to retain the language in §25.130(g)(1)(E)(ii) that requires a stakeholder process and commission approval to determine when and how 15-minute IDR data will be made available on the electric utility’s web portal. "As ARM acknowledged, there are technical problems with implementing this requirement. Methods to gain better access to energy usage data recorded by IDR meters may be considered in future proceedings," Staff said

Staff would decline to make ARM’s proposed change that would eliminate the requirement that a REP be responsible for the cost of system changes necessary to provide enhanced advanced meters requested by the REP. Further, Staff disagrees with ARM’s alternate proposal that would charge a REP only the pro-rata share of the differential costs directly attributable to any individual request for the enhanced meter or feature. "The commission declines to adopt either of ARM’s proposals, in order to prevent costs related to an enhanced advanced meter or feature from being charged to customers that did not cause the costs to be incurred," Staff's proposed preamble states

Staff agrees with TAEBA, Mission:Data, ENEL X, and Sierra Club that the rule should clearly state a customer’s right to authorize its meter data to be available to an entity other than its REP, and has added language to reflect such

Project No. 48525